Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
It's not exactly an "approved" additive...
What is an "APPROVED ADDITIVE" and what FAR requires us to have "APPROVAL"?
It's not exactly an "approved" additive...
You think this might have been a clue?
I'm buying a Chief so have signed up to an Aeronca web board.
Lo and behold the folks there seem sold on adding Marvel Mystery Oil to fuel (4 oz/ gal of 100LL).
I read the same thing in the Bonanza Society magazine.
What's going on?
Is MMO really the dirty little secret in aviation? Anyone else using it or encounter owner groups that promote its use?
What is an "APPROVED ADDITIVE" and what FAR requires us to have "APPROVAL"?
THESE TERMS DO NOT REFER TO SUCH MINERALS COMMONLY KNOWN AS "TOP CYLINDER LUBRICANT", "DOPES", "CARBON REMOVER" WHICH ARE SOMETIMES ADDED TO FUEL OR OIL. THESE PRODUCTS MAY CAUSE DAMAGE TO THE ENGINE (PISTONS, RING STICKING, ETC.) AND THEIR PRESENCE IN AN ENGINE WILL VOID THE OWNER'S WARRANTY.
I don't think I'd mind a snake infestation, and would far prefer one to a rat infestation. Snakes don't burrow or chew wood, they're quiet and would rather just stay out of sight.
Ted? Missa?But what do those dumb engineers at Lycoming know...
Magnets are being sold to cure everything from arthritis to cancer. The people who buy those likely buy the fuel-line magnets, too.
Dan
You could ask the FAA:
They can, and they have. Not directly, mind you, but note that most (all?) AC's reference some regulation. They can and have said that failing to follow a procedure in an AC (ditto the AIM) constitutes violation of the reg for which that AC was written as guidance on how to comply. You may be able to convince the ALJ or NTSB that your alternate method of compliance with the underlying reg was sufficient, but many (most?) times, that won't work. Even if there's no reg specified, they can and have claimed that failing to follow the AC/AIM-recommended practice/procedure was careless/reckless (91.13). Stroll through the NTSB Opinions and Orders and you'll see what I mean.The FAA can not use a AC to violate you, simply because they are non regulatory in nature.
They can, and they have. Not directly, mind you,
As for MMO, if it was so darn good, the oil companies would buy it and put it in their products to obtain a competitive advantage ....
You should use a FAR not a AC to prove your point.
The FAA can not use a AC to violate you, simply because they are non regulatory in nature.
AC = Advisory Circular, They tell us what the FAA likes, not what they demand.
But what do those dumb engineers at Lycoming know...
I seriously doubt that Lycoming's engineers had anything to do with this. Their attorneys and upper management, yes. Engineers...I doubt it.
Not that it makes any difference. If you use MMO, your warranty is void. But this is purely a business decision for Lycoming. Publishing this gives them a "get out of jail free" card regardless of whether MMO does harm or not.
Calling reality names doesn't alter the reality. Just like the other thread about NY state and federal law and handguns, the FAA (and NTSB) have an opinion on how their policies are imposed on you. And since they make the rules, enforce the rules, and adjudicate the enforcement of those rules, a prudent individual makes his own risk decision before deviating from their guidance.gibberish double talk.
Calling reality names doesn't alter the reality. Just like the other thread about NY state and federal law and handguns, the FAA (and NTSB) have an opinion on how their policies are imposed on you. And since they make the rules, enforce the rules, and adjudicate the enforcement of those rules, a prudent individual makes his own risk decision before deviating from their guidance.
I have a "guide" I wrote "Rotor & Wing's Guide to Better Aviation". If you don't follow it you will be violated by the FAA because I make several references to the FAR's in it.
Can the FAA violate you? They can, and they have. Not directly, mind you.
You do get the difference between the AIM and ACs and other stuff published by the FAA, and your own guide, don't you?
But is that 35 years, or the same year 35 times?After 35 years of doing this I think I know the difference Tim. Do you understand sarcasm?
They can, and they have. Not directly, mind you, but note that most (all?) AC's reference some regulation. They can and have said that failing to follow a procedure in an AC (ditto the AIM) constitutes violation of the reg for which that AC was written as guidance on how to comply. You may be able to convince the ALJ or NTSB that your alternate method of compliance with the underlying reg was sufficient, but many (most?) times, that won't work. Even if there's no reg specified, they can and have claimed that failing to follow the AC/AIM-recommended practice/procedure was careless/reckless (91.13). Stroll through the NTSB Opinions and Orders and you'll see what I mean.
That argumnent simply won't hold water, What we are talking about is the FAA violating you for not using the proper fuel in your aircraft. I would wager that many engines were rated on a fuel different than what you are buying at the pump.
Are you saying the AC quoted above will give the FAA the authority to violate any pilot who is using 100LL in an engine rated on 100/130?
As for MMO, if it was so darn good, the oil companies would buy it and put it in their products to obtain a competitive advantage -- like you see with Exxon using ingredients in their Elite oil which the guy behind CamGuard claims are the basis of his CamGuard (he also claims to be the guy who designed those additives for Exxon Elite -- wonder if Exxon is unhappy with his export of technology developed in their lab?).
33.7.3
And I suspect they would violate you if the fuel was not authorized in the TCDS or the engine mfr's Service Instructions, like SI 1070P from Lycoming.That argumnent simply won't hold water, What we are talking about is the FAA violating you for not using the proper fuel in your aircraft. I would wager that many engines were rated on a fuel different than what you are buying at the pump.
No. That is, as you well know, an authorized substitution. I was speaking in general terms about the FAA's penchant for pointing out failure to follow AC's when writing up a pilot for violating the reg underlying the noted AC.Are you saying the AC quoted above will give the FAA the authority to violate any pilot who is using 100LL in an engine rated on 100/130?
And the FAA is pretty much free to write you up for introducing an unauthorized substance into your engine, especially if a bad event results.AS long as any manufacturer doesn't ask the FAA to issue an AD to stop substances from being used in their products we are pretty must free to put in any thing we want.
After 35 years of doing this I think I know the difference Tim. Do you understand sarcasm?
33.7 Engine ratings and operating limitations
(a) Engine ratings and operating limitations are established by the Administrator and included in the engine certificate data sheet specified in §21.41 of this chapter, including ratings and limitations based on the operating conditions and information specified in this section, as applicable, and any other information found necessary for safe operation of the engine.
(2) Fuel grade or specification.
(3) Oil grade or specification
It is a reach to say the MMO at the levels they reccommend are changing the spec or grade of the fuel or oil.
and OBTW the aircraft that were certified on CAR 3 are the ones we use MMO in most.
the manufacturers are the ones that are making the decision as to what oil/fuel grades to be used. not the FAA.
and manufacturers can only make recomendations not rules.
And the FAA is pretty much free to write you up for introducing an unauthorized substance into your engine, especially if a bad event results.
There's one case where the NTSB attributed the accident to the use of MMO, but I have no idea if anyone was violated over it.Please show me where a pilot has used MMO and had a "bad event" and the FAA wrote him up for it.
And the FAA is pretty much free to write you up for introducing an unauthorized substance into your engine, especially if a bad event results.
I got a kick out of this case, where the FAA used MMO in the investigation....
http://www.ntsb.gov/ntsb/brief2.asp?ev_id=20001208X05784&ntsbno=IAD96FA085&akey=1
91.9(a) and 33.7(b). If the fuel or oil spec doesn't include MMO, and the FAA hasn't given other authorization to use it (as they have for CamGuard), then introducing it into the fuel/oil supply would violate those regs.what FAR will they use?
All cylinders on the right engine were sprayed with marvel mystery oil. After a few minutes the pistons freed and the engine rotated.
That's priceless!
91.9(a) and 33.7(b). If the fuel or oil spec doesn't include MMO, and the FAA hasn't given other authorization to use it (as they have for CamGuard), then introducing it into the fuel/oil supply would violate those regs.
I see no such limitation in 14 CFR 33.1 which defines the applicability of Part 33. In any event, the fundamental issue is that of the limitations in the aircraft's or engine's type certification, which according to 33.7 must include fuel and oil grade/spec. If you can find one which doesn't set the specs for fuel and oil to be used, or includes MMO as an authorized additive, I'd like to see it.FAR 33 doesn't apply to CAR 3 built airplanes.
I see no such limitation in 14 CFR 33.1 which defines the applicability of Part 33.
In any event, the fundamental issue is that of the limitations in the aircraft's or engine's type certification, which according to 33.7 must include fuel and oil grade/spec. If you can find one which doesn't set the specs for fuel and oil to be used, or includes MMO as an authorized additive, I'd like to see it.
OK, then what does the type certificate say about what fuels/oils are authorized for use in that aircraft/engine? Remember, if the aircraft is not in conformance with its type certificate or in an approved altered condition, it isn't legally airworthy and 91.9 says you can't fly it. Seems to me that if the engine contains a fuel or lube product not listed in its type certificate, it's not in conformance with its type certificate. What's your basis for the approved altered condition with whatever magic elixir you choose to add to the fuel or oil?The airplane in question in the original post of this thread is an Aeronca Chief. The Aeronca Chief and it's engine were certified under the CAR's.
You're trying to use regulations for aircraft that are certified after the CAR's and apply them to CAR aircraft. You can't do that.
The TCDS (or other appropriate documents) tells you what you're allowed to do in this regard. Anything else is unauthorized. The TCDS doesn't say you can't put auto fuel in the engine of this plane, either, but I'll bet the FAA will be upset if you do so without an autogas STC. Ditto putting in automotive oil. So what makes you think you can legally throw in additives not approved by the FAA for use in that engine?The TCDS doesn't say you can't use an additive. It just spells out minimum fuel octane and grade of oil.
The TCDS (or other appropriate documents) tells you what you're allowed to do in this regard. Anything else is unauthorized. The TCDS doesn't say you can't put auto fuel in the engine of this plane, either, but I'll bet the FAA will be upset if you do so without an autogas STC. Ditto putting in automotive oil. So what makes you think you can legally throw in additives not approved by the FAA for use in that engine?